I need to write an appellate brief for my paralegal clases.Your…

The other idea I had would be to raise a defense of retaliatory eviction and have the landlord testifying that he evicted Sam because Sam complained about the noise.

But I don't have the energy to write the whole paper.

The VRLTA at
http://www.dhcd.virginia.gov/HomelessnesstoHomeownership/PDFs/Landlord_Tenant_Handbook.pdf
states
Article 6.
Retaliatory Action.
§ 55-248.39. Retaliatory conduct prohibited.
A. Except as provided in this section, or as otherwise provided by law, a landlord may
not retaliate by increasing rent or decreasing services or by bringing or threatening to
bring an action for possession or by causing a termination of the rental agreement
pursuant to § 55-222 or § 55-248.37 after he has knowledge that: (i) the tenant has
complained to a governmental agency charged with responsibility for enforcement of a
building or housing code of a violation applicable to the premises materially affecting
health or safety; or (ii) the tenant has made a complaint to or filed a suit against the
landlord for a violation of any provision of this chapter; or (iii) the tenant has organized
or become a member of a tenants' organization; or (iv) the tenant has testified in a court
proceeding against the landlord. However, the provisions of this subsection shall not be
construed to prevent the landlord from increasing rents to that charged on similar market
rentals nor decreasing services that shall apply equally to all tenants.
B. If the landlord acts in violation of this section, the tenant is entitled to the applicable
remedies provided for in this chapter, including recovery of actual damages, and may
assert such retaliation as a defense in any action against him for possession.
The burden of proving retaliatory intent shall be on the tenant.
///

The noise appears to violate the warranty of habitability:

§ 55-248.13. Landlord to maintain fit premises.
A. The landlord shall:
1. Comply with the requirements of applicable building and housing codes materially
affecting health and safety;
2. Make all repairs and do whatever is necessary to put and keep the premises in a fit and habitable condition;

Does this give you enough to work with?